1. Controller and scope
ONMAKE S.r.l., Piazza Giuliano della Rovere 8, 00121 Rome (RM), Italy, VAT IT17261401008, email info@onmake.it, certified email onmake@pec.onmake.it, is controller for its service management, account, contractual relationship, security and support processing. Send privacy requests to info@onmake.it with "Editor Ultra Privacy"; identity documents are not required unless proportionately needed to verify the requester. This address is not represented as the contact of an appointed DPO.
This notice covers Editor Ultra, its connection to the shared ONMAKE account and relevant commercial flows. It supplements the general account notice for the specific processing described here and does not authorise new uses of other applications' data. Editor HTML, OnFirma, AI Save, PageRoll and other ONMAKE products have separate scopes. Reading this notice does not mean consenting to all processing.
2. Roles concerning documents
Where a professional, business or other customer determines the purposes and essential means of processing personal data in their documents, ONMAKE processes it on their behalf under the DPA and instructions. If the customer is itself a processor, ONMAKE acts as sub-processor within the controller's authorisation. Roles depend on actual activities, not plan names. ONMAKE remains a separate controller for its own invoicing, anti-abuse and legal-claims purposes.
People mentioned in customer documents do not become ONMAKE users. Informing those individuals and establishing a lawful basis for the content are the responsibility of the party determining the processing. ONMAKE assists without reusing documents for incompatible purposes. A customer's possible exemption for purely personal or household activities does not exempt ONMAKE from its own applicable obligations.
3. Data and sources
Processing covers email address, account identifier, authentication or recovery credentials and information, security settings, language, optional profile information and organisation membership if enabled. Purchasing requires invoicing information, address and any relevant tax/VAT identifier, certified email and Italian invoice recipient code. Stripe supplies transaction, subscription and refund references and status; ONMAKE does not receive full card numbers through hosted checkout.
Technical data includes IP address, time, browser/device information needed for compatibility and security, authentication outcomes, error and abuse records, versions and languages of contractual documents displayed or accepted, actions and order references. IP-derived location is approximate, not GPS tracking. Local geographical databases do not require each queried IP to be sent to MaxMind or DB-IP.
Content may include text, PDFs, images, metadata, filenames, graphical signatures, certificates embedded in signed documents, attachments and connection details for user-selected servers. It may contain data about clients, represented persons, employees, counterparties, children or others, including special-category and criminal-offence data. Technical ability to upload is not proof of lawfulness: the customer must assess GDPR articles 6, 9 and 10, professional secrecy and necessary safeguards.
Information comes from users, authorised organisational users, operation of the service and strictly necessary providers. Third-party data in support requests should be minimised before sending. Amounts, receipts and administrative decisions do not require collecting the contents of processed documents.
4. Purposes and lawful bases
Account creation, authentication, plan activation, requested processing, service communications and necessary support rely on contract performance or requested pre-contractual steps (article 6(1)(b)). For organisational users not personally party to the contract, contact and entitlement management relies on the legitimate interest in securely providing the organisational relationship (point (f)), subject to proportionality assessment.
Invoicing, statutory tax retention, responses to authorities and mandatory compliance rely on legal obligations (point (c)). Fraud and abuse prevention, security, proportionate evidential records and legal claims rely on legitimate interests (point (f)), unless a specific legal obligation applies. The interest is to protect users, the service and rights; it does not authorise indiscriminate examination of document content.
Editor Ultra subscription does not activate marketing, commercial profiling or non-essential tracking. Any introduction requires relevant information and separate, withdrawable consent where required (point (a)). Service activation and terms acceptance are not consent for these purposes. For content processed as a processor, ONMAKE does not substitute its own lawful basis for the customer's, but follows lawful instructions under article 28.
5. Local processing, servers and copies
The browser may keep open documents, suspended sessions, history, preferences and recovery copies. Persistent browser storage is not the same as saving on ONMAKE servers and may survive closing the tab. Local copies remain subject to the device's settings and security.
Documents the user saves in Editor Ultra (documents, code, spreadsheets) are written to a folder dedicated to that user on the ONMAKE server. The user can delete them from the service; after the subscription ends, only reading, exporting and deleting one's own documents remain possible.
Editor Ultra uses a local PDF engine, but not every operation stays on the device: for operations the local engine does not handle, after an error, and when the local engine is switched off, the PDF goes to the ONMAKE server. The server-side PDF preview is held in memory for at most thirty minutes. Document conversions use the ExactDOC engine installed on the same machine as the service. The server downloads from public addresses only the images contained in the user's own OnFirma signatures, when these are inserted into a document.
The location declared by ONMAKE is: application server on Microsoft Azure, Italy North region; account data in the Supabase project in the EU Frankfurt region; website and service email on Aruba in Italy. For signature verification, trust lists and revocation services may be consulted.
The publishing function transfers files to the FTP, FTPS or SFTP server the user indicates, with the credentials the user enters. The list of connections (address, user, folder) is kept in a separate store per user; passwords are not saved on the server. A destination chosen by the user may be outside the EU: the customer must check that choice. The OnFirma integration reads the user's content within the plan's limits and the command given and does not make it public automatically.
6. Recipients and access
Data is accessible to authorised ONMAKE personnel bound by confidentiality and necessary hosting, database, email, payment, invoicing, support and security providers under appropriate arrangements and their actual roles. Microsoft Azure and Supabase support infrastructure; Aruba supports the website and email; Openapi S.p.A. supports invoice transmission; the Italian Revenue Agency receives tax flows and provides preservation where activated. Stripe acts in the roles applicable to each activity, including independently for its own legal and payment-security duties; it is not uniformly classified as ONMAKE's processor.
Providers of locally installed conversion software do not receive documents merely because their software runs. Actual recipients and sub-processors relevant to content must be identified in the DPA-related list available before processing. Authorities, confidential advisers and parties to corporate transactions may receive data only as necessary and subject to applicable safeguards. Documents are not publicly disclosed by default.
AI providers chosen by the user (document 07) are not recipients chosen by ONMAKE: they receive data only if the user connects their own assistant, under that provider's terms and notice. An external AI connecting through MCP or REST API is also chosen by the user. Each user may revoke the keys and authorisations they create.
7. International transfers
European server locations do not automatically exclude access or processing outside the EEA by provider groups. ONMAKE permits a transfer only on a GDPR Chapter V basis: an applicable adequacy decision verified for the recipient, or appropriate safeguards such as relevant standard contractual clauses, transfer assessment and supplementary measures where necessary. General acceptance of terms is not used as derogation consent for routine transfers.
Customers and individuals may request recipient identities, countries, applicable safeguards and copies of relevant information from info@onmake.it, with only unnecessary confidential details redacted. A new transfer of entrusted content must also comply with the DPA and customer instructions. The Italy/EU commercial scope does not remove these European obligations.
8. Retention
Documents saved in the service remain until the user deletes them or the service ends; after termination reading, exporting and deleting are available under document 12. The server-side PDF preview expires thirty minutes after creation.
Invoices and tax records are kept for ten years or any longer legally required period; deleting the account does not delete them. Shared-account data remains while the account is needed for other requested services; ending Editor Ultra alone does not delete it. Contract data and strictly necessary evidence are kept for the relationship and, to the extent needed for obligations and defence, for the applicable limitation period. They do not include the content of the customer's documents.
The log of agent calls (app, user, key, tool, outcome, date; never document content) and technical logs are kept for the time needed for security, limit control and abuse prevention. Support data is kept for the time needed to handle the request; unnecessary attachments are removed on closure.
Local storage, sessionStorage and IndexedDB may persist until the user clears them, the browser removes them or a service function intervenes; remote deletion of copies on unreachable devices is not promised. Cookies and lifetimes are described in document 04.
9. Security, automation and AI
ONMAKE adopts measures proportionate to risk, including per-user authorisation, separation of folders and connection stores per user, channel protection, subscription, block and suspension checks during use, limits on attempts with invalid keys, updates and incident handling. The measures contractually owed for content are in annex B to the DPA. No certifications, absolute absence of vulnerabilities or end-to-end encryption are claimed.
Editor Ultra lets users connect an AI assistant of their choice. ONMAKE does not supply AI models of its own and does not send customer content to AI providers: data reaches an AI provider only if the user connects their own assistant, and on that provider's terms (document 07). Internal use of AI tools by staff is distinct: customer content is not sent to such tools without a separate assessment and information.
Automatic controls on limits, payment and security may refuse or limit operations. They are not described as commercial profiling or professional decisions about content. Users may request human review of a block at info@onmake.it. Before introducing decisions based solely on automated processing with legal or similarly significant effects, ONMAKE carries out the assessment and provides the information and safeguards required by Article 22 GDPR.
10. Rights, required information and changes
Where applicable, individuals may request access, rectification, erasure, restriction and portability, object to legitimate-interest processing and withdraw consents actually given without affecting earlier lawfulness. ONMAKE responds without undue delay and normally within one month, extendable only in the circumstances and with the notice required by the GDPR. Requests are normally free; exceptions must be justified under law.
For data in documents processed on behalf of a customer, ONMAKE forwards the request to the competent party and assists. GDPR portability concerns the data and conditions in article 20 and does not replace broader contractual document return. Individuals may complain to the Italian Garante or the authority in their habitual residence, workplace or place of the alleged infringement, and seek judicial remedies.
Email and information necessary for performance or tax obligations are required for the corresponding service; optional profile information and promotional consent are not. Refusing unnecessary information does not prevent the basic service. Material notice changes are communicated appropriately before new processing; an update cannot legitimise incompatible processing or replace required consent.